REMITTANCE

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

Sophie Dworetzsky

In this month’s update, Sophie Dworetzsky (Lombard Odier) reports the late change to the IHT reforms, the sharp increase in transparency and compliance obligations and some of the latest court rulings that matter.

Alice Pearson

The Temporary Repatriation Facility could create significant tax savings for some. Alice Pearson (Mercer & Hole) highlights some practical considerations and areas of complexity.

Dominic Lawrance

Sophie Dworetzsky

They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) comment on the end of the remittance basis, the ‘absolute mess’ that is the double remittance situation and a potentially worrying change in HMRC’s view on the taxation of capital payments in ancillary relief on divorce.

Peter Vaines

Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...

Costs awarded because of taxpayer’s unreasonable conduct: In HMRC v Mattu [2025] UKUT 410 (TCC) (16 December 2021), the UT awarded HMRC £5,000 in costs under rule 10(3)(d) of the UT rules (SI 2008/2698), confirming that there is no requirement for a...

Henry Lowe

Henry Lowe (Mercer & Hole) explores how best to fund a divorce payment now that the non-dom regime has been abolished.

Edward Reed

Kazia Gagg

Edward Reed and Kazia Gagg (Macfarlanes) consider what’s in store for private clients under the new Labour government and comment on a number of tribunal decisions on the remittance rules, SDLT and entrepreneurs’ relief.

Edward Reed

Sam Epstein

Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of ‘service’ under the remittance basis rules are reviewed by Edward Reed and Sam Epstein (Macfarlanes).

Debt indemnity arising from share sale did not give rise to a remittance to the UK

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